Privacy Policy

P ursuant to the Personal Information protection and Electronic Documents Act (PIPEDA).
CustomEyes Inc.

Protecting the privacy of your personal information is important to us.

W e are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the optometric and Ophthalmic services that we provide. We are committed to being open and transparent about how we handle your personal information. This document describes our privacy policies

Effective Date and Changes

W e will comply with the terms of this privacy policy while it is in effect.
We reserve the right to modify the policy at any time as may be required to comply with privacy legislation and the revised privacy policy will then apply to all personal information. This policy will be in effect from Jan 1, 2016 until the date an amended policy is published. Any changes or amendments to our privacy policy will be posted in our office, have copies available and publish it on our website.

What is Personal Information?

P ersonal information is information about an identifiable individual. Personal information includes information that relates to any personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), health (e.g. health history, health conditions, health services received by them) or activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
Personal information does not include your business address and telephone number, which is not protected by privacy legislation.

Who We Are

C ustomEyes Inc. includes any optometrist or health care professional, all employees, staff and student trainees authorized to collect, use or disclose personal information.
We use a number of consultants and agencies that may, in the course of their work for us may, where necessary, have limited access to personal information we hold. These include, but are not limited to; ophthalmologists to whom we refer, third party insurers, contact lens companies, lens manufacturing companies, opticians, IT consultants, office security and maintenance, bookkeepers and accountants, temporary workers to cover holidays, credit card companies, collection agencies, website managers and lawyers.
We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

Collecting Personal Information: Primary Purposes About Patients

C ustomEyes Inc. collects, uses and discloses personal information in order to serve our patients. For patients, the primary purpose for collecting personal information is to provide optometric services. For example, we collect information about your health history, including family history, physical condition and function and social situation as necessary to help us assess your eye care needs and to advise you of options and then to provide the eye care you choose to have.
We may communicate this information to other regulated health practitioners, technicians or individuals authorized to work in our practice as part of your continuing care. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that are occurring over time. It would be rare for us to collect information without the patient’s written, oral or implied consent, but this could occur in an emergency (e.g. the patient cannot communicate) or where we believe you would consent if asked and it is impractical to obtain consent (e.g. a family member passing a message on from our patient where we have no reason to believe that the message is not genuine).

Our Website

P lease note that the CustomEyes website uses remarketing with Google Analytics to advertise CustomEyes services and our website content online. Third-party vendors, including Google, may show these ads on sites across the Internet. CustomEyes and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads linking to relevant pages on www.CustomEyes.CA, based on past visits to the CustomEyes.CA website. Please be assured that this data does not link to or include any client information, nor are the statements above affected.

About Contract Staff, Volunteers and Students

F or people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting your personal information is to ensure we can contact you in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending our paycheques, year-end tax receipts).
Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency (e.g. a SARS outbreak) or to investigate a possible breach of law (e.g. if a theft were to occur in the office). If you as a contract staff person, volunteer or student, wish a letter of reference or an evaluation, we will collect information and your work-related performance and provide a report as authorized by you.

About Contract Staff, Volunteers and Students

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes.
The most common examples of our related and secondary purposes are as follows:

  • To invoice patients for optometric services, products or treatments that were not paid for at the time the service was provided, to process credit card payments or to collect unpaid accounts either ourselves or through a collection agency or lawyer.
  • When the cost of some optometric services, products or treatments provided by the practice to patients is paid for by third parties (e.g. Department of Health, private insurance and various social assistance programs). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate patient entitlement to this funding.
  • To advise you, by telephone, mail or email that your vision and eye care needs or treatment should be reviewed (e.g. to schedule an appointment, to ensure that your eye glasses and/or contact lenses are still functioning properly and appropriate for your current needs and to consider modifications ore replacement).
  • To advise patients, prospective patients and others of special events or opportunities (e.g. a seminar, development of a new service, arrival of a new product) that we have available.
  • Our office reviews patient and other files for the purpose of administration, business planning and ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g. auditors, lawyers, practice consultants, quality assurance programs) may, on our behalf, do audits and continuing quality improvement reviews of our practice, including reviewing patient files and interviewing our staff. In rare cases, our practice or our consultants may make inquiries to verify that the information we have about you is accurate.
  • Optometrists are regulated by the College of Optometrists, which may inspect our records and interview our staff as a part of their regulatory activities in the public interest. In addition, as professionals, we report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our practice believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our patients, or other individuals, to support the concern (e.g. improper services). Also, like all organizations, various government agencies (e.g. Canada Customs and Revenue Agency, Information and Privacy Commissioner, Human Rights Commission, et cetera) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g. lawyers, accountants) who will investigate the matter and report back to us.
  • Patients or other individuals we deal with may have questions about our products or services after they have been received. We also provide ongoing optometric services for many of our patients over a period of months or years for which our previous records are helpful. We retain our patient information for a minimum of ten (10) years after the last contact to enable us to respond to those questions and provide these services.
  • Halifax Optometry Clinic Inc. operating as Insight Optometry Group or its assets were to be sold, the prospective purchaser would want to conduct a “due diligence” review of the practice records to ensure that it is a viable business that has been honestly portrayed to the prospective purchaser. This due diligence may involve some review that may include releasing personal information. The prospective purchaser would not be allowed to remove or record personal information and, before being provided a review of the clinical files and records, the prospective purchaser must provide a written promise to keep all personal information confidential. Only a reputable purchaser who has already agreed to purchase the practice or its assets would be provided, at closing, complete access to personal information. The purchaser would be required to maintain the same principles of privacy as established under the present privacy legislation. You can choose not to be part of some of these related or secondary purposes (e.g. by declining to receive notice of special events or opportunities, or by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g. external regulation).

Protecting Personal Information

We understand the importance of protecting personal information. For that reason we have taken the following steps:

  • CustomEyes Inc. staff will safeguard, according to strict standards of security and confidentiality, any information you share with us.
  • CustomEyes Inc. will limit the collection, use and disclosure of client information to what is necessary to deliver comprehensive health care services
  • CustomEyes Inc. will only permit its authorized employees - those who are either providing direct health care service or providing administrative support - to have access to client information. In summary, only those staff who have a need to know or a right to know will have access to client information. This will apply to information in all forms - electronic client charts, administrative forms, and all other electronically-based information.
  • All CustomEyes Inc. employees will sign an individual confidentiality and privacy commitment upon employment. This commitment will be reviewed on a regular basis. All employees will undergo rigorous privacy education and regularly review privacy policies and procedures. Employees who violate our Privacy Commitment will be subject to our normal performance management process.
  • CustomEyes Inc. will not reveal client information to any external organization unless we have previously informed the client in disclosures or agreements, have been authorized by the client, or are required to do so by law.
  • Whenever CustomEyes Inc. hires other organizations to provide support services, they will be required to conform to our privacy standards and to allow us to audit them for compliance.
  • CustomEyes Inc. will not use or share - internally or externally - personally identifiable medical information for any purpose other than the provision or administration of a client's health service or account, or as disclosed to the customer when the information is collected, or to which the customer consents.
  • CustomEyes Inc. will strive to keep all client files complete, up-to-date and accurate. We will advise clients how and where to conveniently access their health record information and how to notify us of errors, which will be promptly corrected
  • CustomEyes Inc. has appointed a Privacy Officer to oversee, monitor and report all client privacy issues and concerns. You may contact the privacy officer at:
Privacy Officer
CustomEyes Inc.
2901 Markham Rd.
Toronto, Ontario, M1X 0B6
Tel: 416.335.1234
Fax: 416.335.4321

Retention and Destruction of Personal information

W e need to retain personal information for some time to ensure that we can answer any questions you might have about the services we provided to you and for our own accountability to external regulatory bodies. In compliance with the requirements of other legislation, we maintain our patient records for a minimum of ten (10) years in electronic format under Electronic Medical Record Systems. We also maintain onsite and off site backups to secure locations. We keep any personal information relating to our general correspondence (i.e. with people who are not patients), newsletters, seminars and marketing activities for about 24 months after the newsletter ceases publication or a seminar or marketing activity are over.
You can ask us, in writing, to restrict our uses and disclosures of personal information at any time. We will also discontinue to use or to disclose your personal information after a written revocation of your implied or informed consent is received, unless we have already acted in reliance upon this consent. We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that information on the hard drive is destroyed. Alternatively, we may send some or the entire patient file to our patient.

You Can Look At Your Information

W ith rare exceptions, you have the right to see what personal information we hold about you. All you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g. short forms, technical language, et cetera).
We will need to confirm your identity, if we do not know you, before providing you with this access.
We reserve the right to charge a nominal fee for such requests. We may ask you to put your request in writing. If we cannot give you access, we will notify you within thirty (30) days if at all possible and provide the reason, as best we can, as to why we cannot give you access. If you believe there is a mistake in the information we have about you, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are incorrect. Where a mistake has been made, we will make the correction and notify anyone to whom we sent this information. If we do not agree that a mistake has been made, we will include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

Do You Have A Question?

O ur Privacy Officer will attempt to answer any questions or concerns you might have. If you wish to make a formal complaint about our privacy practices or the application of those practices, you may make it in writing to our Privacy Officer. He/She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
This policy is made pursuant to Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. The Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at: 112 Kent Street, Ottawa, Ontario, K1A 1H3 Phone (613) 995-8210 / Toll-Free 1-800-282-1376 Fax (613) 947-6850 / TTY (613) 992-9190 , web site www.privcom.gc.ca